Anna Oberschelp de Meneses, Ulrike Elteste and Kristof Van Quathem of Covington and Burling write:
On December 2, 2019, the German Supervisory Authorities issued a report evaluating the implementation of the EU General Data Protection Regulation (“GDPR”) in Germany. The report describes the Supervisory Authorities’ experience thus far in applying the GDPR and lists the provisions of the GDPR they see as problematic in practice. For each of these provisions, the report discusses the perceived problem and proposes a solution.
The report begins by noting that the GDPR has significantly increased the workload of German Supervisory Authorities over the past year and a half. This is due not only to an “enormous growth” in the number of complaints and consultation requests received, but also additional work resulting from the GDPR’s cross-border cooperation procedure.
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